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Office of Medicaid (MassHealth) Review of Controls over Pharmacy Claims

July 25, 2013 · Office of Medicaid (MassHealth) · Read the full official report (PDF) ↗ · official site ↗

Published July 25, 2013 Audit covers July 1, 2009 – June 30, 2011 Under Suzanne M. Bump · 2011–2023

In plain English
MassHealth paid over $1 billion in pharmacy claims, but its main data system was missing or mislabeling key details needed to spot suspicious prescription activity.
source
“MassHealth paid approximately $1 billion in pharmacy claims in total during fiscal years 2010 and 2011.”
Read the plain-English breakdown
What is this?

This is a state audit of MassHealth’s controls over pharmacy claims from July 1, 2009 through June 30, 2011.

“In accordance with Chapter 11, Section 12, of the Massachusetts General Laws, the Office of the State Auditor (OSA) conducted an audit of pharmacy claims paid during the period July 1, 2009 through June 30, 2011.”
Why was it audited?

The auditor reviewed the program because Medicaid is a major public program with known risks of fraud, waste, abuse, and mismanagement, especially around drugs with high abuse potential.

“Our audit was conducted as part of the Office of the State Auditor’s ongoing independent statutory oversight of the Commonwealth’s Medicaid program.”
Why it matters

If MassHealth’s records are incomplete or inaccurate, auditors and investigators may have trouble finding billing problems or possible fraud.

“Without complete and accurate claims information, independent reviewers of the Pharmacy Program cannot effectively identify trends and anomalies indicative of billing irregularities and potentially fraudulent activities.”
What's in it for me?

For taxpayers and MassHealth members, better pharmacy data can help protect public money and support safer oversight of high-risk prescription drugs.

“As with any government program, the confidence of the public is essential to the Pharmacy Program’s success and continued support.”
The bottom line

The audit’s main finding was that MassHealth’s Data Warehouse did not have enough reliable information to fully review pharmacy claims.

“Our audit found that MassHealth’s Data Warehouse does not contain all of the information necessary to effectively review the Pharmacy Program.”
What happens next

The auditor recommended that MassHealth improve its Data Warehouse by adding provider identifiers, clearly labeling compound drugs, and accurately transferring refill information.

“MassHealth should improve the completeness and accuracy of claims information within the Data Warehouse by adding a data field to capture the prescribing provider’s NPI number; identifying compound drugs with a descriptor (e.g., “Compound”); and transferring the “Allowed Number of Refills” data from POPS to both MMIS and the Data Warehouse for all prescription drug claims.”
Why it's significant

This matters because the audit found large numbers of claims where provider or drug information was missing from the main review system, including Schedule II drugs with high abuse potential.

“During the audit period, MassHealth paid 1,259,226 claims, totaling $66,575,674, for Schedule II pharmaceuticals.”
Jargon, unpacked

The Data Warehouse is MassHealth’s main place for storing claims data so reviewers can search it for patterns that may need investigation.

“The Data Warehouse is the source from which all pharmacy claims can be queried and analyzed by independent reviewers, including the Office of the State Auditor (OSA), to identify trends and anomalies that may warrant further investigation.”

3 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

MassHealth's Data Warehouse lacked complete and accurate pharmacy claims data needed to review the Pharmacy Program.
recordkeeping/documentationinternal controlsfraud/theft

Why it matters: Independent reviewers could not effectively identify billing irregularities, fraud indicators, and other anomalies in pharmacy claims.

Standard: Chapter 94C, Section 23(b), of the Massachusetts General Laws prohibits refills of Schedule II drugs. ( Chapter 94C, Section 23(b), of the Massachusetts General Laws; U.S. Controlled Substances Act; Chapter 11, Section 12, of the Massachusetts General Laws )

3 recommendations
  • MassHealth should add a Data Warehouse field to capture prescribing providers' NPI numbers.agency: agreed
  • MassHealth should identify compound drugs with a descriptor.agency: disagreed
  • MassHealth should transfer allowed refill data from POPS to MMIS and the Data Warehouse for all prescription drug claims.agency: agreed
Agency response & Auditor reply
Agency: "MassHealth is in the process of evaluating the options for updating its systems to ensure that all NPIs are captured in the Data Warehouse, which we agree will further our program integrity efforts."
Auditor: "Overall, EOHHS’s willingness to collaborate with OSA in resolving these data problems should serve to enhance the integrity of its Pharmacy Program."

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